The types of information we collect depend on the nature of your interaction with us. You may choose not to provide us with your personal information. However, if you make this choice we may not be able to provide you with the Product, Service, or information that you requested.
Contact or account information
We may collect basic contact or account information about you such as your name, email address, organization, job title, business address and/or business or mobile phone number when you:
We may also compile the history of your interactions and transactions with us, such as your past purchases and requests.
We collect certain payment and billing information when you purchase or register for certain paid Products and Services, such as the name and contact information of your accounting representative. We do not collect or store any banking or credit card information in connection with your transactions with us. If you choose to purchase our Products or Services by using a payment or credit card via our Websites, your card information will be processed through a secured and compliant third-party payment processing application to which Devolutions subscribes, and we do not therefore process, collect, store or even have access to your card information. We strongly recommend you not to submit or send us your banking or payment card information, whether by email, phone, mail or fax, in which case such information will be deleted or destroyed forthwith.
Information you provide through our Websites, blogs and online forums
We may collect or display certain limited information when you provide feedbacks, questions or comments or when you participate in any interactive features, surveys, contests, promotions, sweepstakes, activities or events through our Websites, online blogs, newsletters and forums.
As an example, your name, username and gravatar (or profile picture) may appear next to your comment or question that you submit on our blog (depending on the information and preferences that you registered when creating your blog account with our third-party service provider).
In addition, any such information that you decide to disclose or share will become public information which could be read, collected, copied, modified or otherwise used by other users, service providers or operators of these blogs and forums. We are unable to control such uses of your information, and by using such features on our Websites you consent and assume the risk that the information provided by you may be viewed and used by third parties as described above. You should therefore exercise caution when deciding to disclose your personal information through these features.
Collection of information using cookies, web beacons and other tools
We may also collect information that is related to you but that does not directly identify you, such as your internet protocol address, your internet domain name, the region or general location where your computer or device is accessing the internet, the web browser and operating system used to access our Websites, and information regarding your use of and activities on our Websites such as the pages or files visited, the time spent on each page or file, or the time and date of each visit or use. Devolutions may collect this information automatically as you browse our Websites through the use of log files, web beacons or other electronic tools.
Cookies and Web beacons
Cookies are pieces of data that a website transfers to a user's hard drive or mobile device for record-keeping purposes and to recognize a person as a previous user of a website. Web beacons are transparent pixel images that are used in collecting information about website usage, e-mail response and tracking. The information collected through cookies, web beacons, log file information and other electronic tools (e.g. the web pages you visit on our Websites and navigation patterns, the date and time of your visit, the number of links you click, the functions you use or the data you downloaded from our Websites) is used and analyzed to improve and personalize our service to you (e.g., user ID and password prompts, language preferences), to provide enhanced convenience, use and functionality of our Websites and to aggregate traffic data (e.g., what pages are the most popular). We may also use this information to help diagnose problems with our server and to administer our Websites, analyze trends, track visitor movements, and gather broad demographic information that assists us in identifying visitor preferences.
We also use specific tools in our emails sent to our users to track which emails are opened and which links are clicked by recipients. We use this information to evaluate the effectiveness of our marketing campaigns and to allow for a more accurate reporting and improvement of our Products and Services. None of the tracking information that we collect is or can be connected to the identities or other personal information of individual users. We also do not track the users of our Websites when they cross to third party websites and we do not provide targeted advertising to them.
Our Websites also uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help our Websites analyze how users use the site. The information generated by the cookie about your use of our Websites (including your IP address) will be transmitted to and stored by Google on its servers. To learn in more details how Google will use such data, please review their privacy statement. By using our Websites, you consent to the processing of data about you by Google in the manner and for the purposes set out above and in accordance with Google’s own privacy policies, and Devolutions disclaims any responsibility or liability in that respect.
Information that we collect from third parties
Your administrator or other users of your organization
Your administrator or other users of your organization may provide information about you when they purchase or subscribe to a Product or Service on behalf of your organization, or when they register or activate a Product license. For example, an administrator may provide your contact information when they designate you as the billing or technical contact on your company's account, or if they request that we contact you for technical assistance.
Devolutions allows you to use certain features of its Websites through integrated third-party applications or accounts. For example, you will need to log in to your Disqus account to interact and write comments on our blogs. The information provided to these third parties to create such accounts and to use these third-party applications through our Websites is not automatically shared with Devolutions, and Devolutions does not collect or store this information (other than the information displayed in connection with your use of such features on our Websites). We recommend that you review the privacy policies that govern the use of such third-party applications and accounts to understand how your personal information is collected and processed by these service providers.
Information that you submit to our Services
We may process information (including personal information) that you submit to the Services or in the course of using them. Such processing is made by us on your behalf in our capacity of a “data processor” in accordance with the terms of our Data Processing Addendum, which you may find here.
Our legitimate interests
To the extent the European Union’s General Data Protection Regulation (GDPR) applies to the collection and processing of your personal data, the legitimate interests on which Devolutions bases the process of your information include the following:
If the GDPR does not apply to the collection and processing of your personal information, you are deemed to consent to the use and processing of your personal information for all the purposes identified above (as applicable) by using our Websites, Products or Services, or by otherwise interacting with any other aspect of our business.
We may share information we collect about you in the ways discussed below. Please note that Devolutions does not share, sell, trade or lease your information to or with others for any commercial or mercantile purposes.
The information that we collect from you is stored in cloud databases hosted on third-party servers. These third-parties do not use or have access to your information for any purpose other than storage and retrieval of information and are contractually required to maintain adequate privacy and security safeguards that comply with applicable laws.
Third-party service providers
We work with third-party service providers, some of which are located outside of the European Economic Area, to provide development and integration of applications within our Websites, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, analysis and other services for us. Devolutions may share your information with them only to the extent necessary for the performance of their services, and these service providers are contractually required to maintain adequate privacy and security safeguards that comply with applicable laws.
Our Websites offer publicly accessible forums in which users may ask questions or provide comments on our Products and Services through their Devolutions® Cloud account. If you decide to post a question or comment on our community forums, you should be aware that any information that you provide, as well as certain profile information such as your username, your gravatar (or profile picture), the date of your registration and your last log on date, may be read, collected, and used by any member of the public who accesses them, and your posts and profile information may remain visible on our forums even after you close or delete your account. We urge you to consider the sensitivity of any information you input into these community forums. To request removal of your information from publicly accessible forums operated by us, please contact us as provided below. In some cases, we may not be able to remove your information, in which case we will let you know if we are unable to and why.
Links to other websites
Social medias applications and widgets
Our Websites use widgets and social media features such as Facebook, LinkedIn, Twitter and others. If you choose to use such widgets or features on our Websites, they may collect certain information such as your IP address, which page you are visiting on our Websites, and may set a cookie to enable the feature to function properly. Devolutions does not collect, process or store such information. Your interactions with these widgets and features are governed by the privacy statements of the companies providing them, and you should therefore review them to better understand how your information will be collected and processed.
Managed accounts and administrators
If you register for or access our Products or Services using an email address with a domain that is owned by your employer or organization, and such organization wishes to establish an account or activate a license on your behalf, certain information about you including your name, contact information and past use of your account may become accessible to that organization’s administrator and other users sharing the same domain. We may also share your contact information with other users of your organization to facilitate service-related requests.
With your consent
We share information about you with third parties when you give us your express consent to do so. For example, we sometimes display personal testimonials of satisfied customers on our Websites or blogs along with their name and picture, with their prior express consent.
Change of control or sale of assets
If Devolutions becomes involved in a merger, acquisition, securities offering, bankruptcy, reorganization, dissolution or other similar transaction, we may share your personal information in connection with any such transaction. To the extent possible, we will take commercially reasonable measures to limit the quantity of personal information transferred and make sure that such transfers are governed by appropriate confidentiality, privacy and security safeguards.
Other instances where we may be required to share your personal information
Sharing of non-personal information
We may also gather aggregated data about our clients and Websites visitors and disclose the results of such aggregated (but not personally identifiable) information to our partners, service providers, advertisers and/or other third parties for marketing or promotional purposes.
You will not receive our communications or marketing materials (such as our Devolutions Newsletters) unless you have expressly requested or consented to be added on our marketing list. Devolutions does not sell or rent its marketing list to other parties for marketing uses. If you purchase one of our Products or Services for the first time, you will also receive an email inviting you to become a member of our “Devolutions Force” forum and to create an account for such purpose. This membership is optional and is offered only to provide you a better experience when using our Products and Services. You will be entirely free to decline or ignore our invitation, in which case no other communications will be sent to you in that regard. The fact of declining or ignoring our membership invitation will by no means affect your ability to use the Products and Services that you purchased from us.
Privacy laws allow you to exercise certain choices and rights in respect of the information that we hold or process on you, as described below. Some of these rights can be exercised by logging into your Devolutions® Cloud account and using available settings (but where the Services or accounts are administered for you by an administrator, you may need to contact your administrator to assist with your requests first). Otherwise you may contact us in writing at firstname.lastname@example.org or by contacting our support service (https://devolutions.net/support). All requests will be treated within a time frame of thirty (30) days, at no cost.
Please be aware that your request may be limited in certain cases, for example if you ask to delete information which we or your administrator are permitted by law or have compelling legitimate interests to keep. Where you have asked us to share data with third parties, or if you provided your information to third parties through our Websites, you will need to contact those third-party service providers directly to have your information deleted or otherwise restricted.
If you have unresolved concerns, you may have the right to complain to a data protection authority in the country where you live, where you work or where you feel your rights were infringed.
Right of access
Upon request, we will provide you with reasonable access (physical or online) to your personal information in accordance with applicable laws. Such access may be granted to confirm that we are processing your personal information, how we have used it and to whom we might have transmitted it. You may also access your information to verify its accuracy or to modify your preferences regarding how we use or disclose it. If you created a Devolutions® Cloud account, you may also access some of your information by logging into your account.
When applicable, we will provide you with an electronic file of your basic account information in conformity with the data portability principle. Data portability is the ability to obtain some of your information in a format you can move from one service provider to another. Depending on the context, this may apply to some of your information, but not necessarily to all of your information.
Right to rectification or erasure
Deletion of your Devolutions® Cloud account
If you wish to delete your Devolutions® Cloud account, you or your administrator may be able to do so by logging in to your account and click on the “Delete Account” button. If you are unable to delete your account for any reason, please contact our support team. Please be aware that there may me a delay between the deletion of your account and the erasure of your account information on our databases, and that once such erasure is completed we will no longer be able to retrieve your information. Please note also that the deletion of your account will not delete your information already visible to other users based on your past participation within our online features, such as our community forums.
Restriction on processing
In some cases, you may ask us to restrict the processing of your information where you believe we don't have the appropriate rights to do so. Where you gave us consent to use your information for a limited purpose, you can contact us to withdraw that consent, but this will not affect any processing that has already taken place at the time. When you make such requests, we may need time to investigate and facilitate your request. If there is delay or dispute as to whether we have the right to continue using your information, we will restrict any further use of your information until the request is honored or the dispute is resolved.
Right to object
If you are a resident of the European Union or the European Economic Area, and where the processing of your information is based on our legitimate interests as explained above, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons.
If the processing of your information is based on your express consent, you have the right to withdraw your consent to the processing of such information at any time, as explained in Section V above
Verification of your identity
To protect your privacy and security, we will take steps to verify your identity before granting access to your information or allowing the exercise of your rights mentioned above. While we will make reasonable efforts to accommodate your request, we also reserve the right to reject it or to impose certain restrictions or requirements if we reasonably believe that (i) this may put the security of your personal information at risk, (ii) the disclosure of such information would likely hinder an inquiry relating to the prevention, detection or repression of crime or statutory offences, (iii) the disclosure of such information would affect judicial proceedings in which you have an interest, or if otherwise required or permitted by applicable laws. If for some reason we decide to deny your request, we will provide you the grounds on which we have based our decision, to the extent possible.
Security and confidentiality of your information
However, as no security system is impenetrable and given the inherent nature of the Internet, we cannot guarantee that data, during transmission through the Internet or while stored on our systems or otherwise in our care, is absolutely safe from intrusion by others.
If the Products, Services or accounts are made available to you through your organization (e.g., your employer), we retain your information as long as required by the administrator of your account.
Information about you that is no longer necessary but relevant to improve or develop our Products and Services may be de-identified and aggregated with other non-personal information. This information will be de-associated with your name and other identifiers.
Devolutions is located in Canada, which was recognized by the European Commission as a jurisdiction ensuring an adequate level of protection for the purpose of transferring personal data outside of the European Union. However, most of the information (including personal information) that we collect from you and that we process via our Websites and Services are hosted on servers owned or controlled by third-party service providers that we engage. Such servers may be located anywhere in the world, including within countries other than Canada or from the European Economic Area, and these other countries may not have equivalent privacy and data protection laws. When we transfer information (including personal information) of customers or users located in the European Union or the European Economic Area, we ensure that the organizations to which such information is transferred offer appropriate safeguards such as the EU-U.S. Privacy Shield Framework, European Commission-approved standard contractual data protection clauses, binding corporate rules for transfers to data processors, or other appropriate safeguard mechanisms.
Information processed or stored with or through our Products and Services
If you use one of our Services to store your information or information that you have collected from third parties, such as Devolutions® Cloud Database, Devolutions® Password Hub, Devolutions® Online Drive or Devolutions® Online Backup, our obligations as processor or sub-processor of such information will be governed by the terms of our Data Processing Agreement.
Many of our Products and Services are intended for use by organizations. Where they are made available to you through an organization (e.g. your employer), your account or use of such Products and Services may be controlled by, or be under the responsibility or supervision of, other persons of your organization. If this is the case, please direct your data privacy questions or requests to such designated person(s) in your organization, who may then contact us as provided below.
Our Websites, Products and Services are not designed or structured to attract or be used by children or minors, and we do not intend to collect personal information from any such person. In any case, we will not use and will delete as quickly as possible any such information. If you believe that we might have any such information, please contact us at email@example.com.
Lavaltrie (Québec) Canada, J5T 1M1
Email : firstname.lastname@example.org
GDPREP.ORG has been appointed as Devolutions’ representative in the European Union and United Kingdom for data protection matters pursuant to Article 27 of the EU GDPR and of the UK GDPR. GDPREP.ORG can be contacted in addition to Devolutions’ points of contact above, at the following coordinates:
UK Address / Contact Information
a: Studio Office, 25A Archer Road, Penarth, CF64 3HJ
t: +44 (0) 7810 883333
EU Address / Contact Information
a: Suite 10357, 5 Fitzwilliam Square, Dublin 2, Ireland, D02 R744
t: +44 (0) 7810 883333
Last update : January 25, 2019
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